…a missed chance that the GCC has not gone the same way so far. [1] Source: Kearney analysis GCC e-commerce sector, https://www.consultancy-me.com/news/3092/gccs-e-commerce-sector-surging-ahead-amid-covid-19. [2] The term GCC refers to the Cooperation…
…[40] V.Chand, G. Lembo, Intangible Related Profit Allocation within MNEs based on Key DEMPE Functions, International Tax Studies, Journal Articles & Papers IBFD (2020) available on https://www.ibfd.org/IBFD-Products/Journal-Articles/International-Tax-Studies/collections/itaxs/html/itaxs_2020_06_o2_1.html [41] See https://www.un.org/development/desa/financing/sites/www.un.org.development.desa.financing/files/2020-08/TAX%20TREATY%20PROVISION%20ON%20PAYMENTS%20FOR%20DIGITAL%20SERVICES.pdf…
…inspiration from comparable dispute resolution regimes that deal with taxation matters (Investor-State Dispute Settlement, International Commercial Arbitration and World Trade Organization dispute resolution mechanism). It concludes by providing proposals to…
…FS entities operate, most importantly against the activities that can be lawfully carried out in compliance with applicable regulatory requirements. Any redundant complexity should indeed be kept at an absolute…
…craft is used for commercial or private purposes. According to the EU Commission, the lack of a case-by-case verification of the charterer’s commercial purpose constitutes a breach of the Energy…
…by an Italian company (‘Itaco’) to its controlling shareholder, a Luxembourg sub-holding (‘Luxco’) which, in turn, was controlled by another Luxembourg company. Interest paid by Itaco accrued on a loan…
…resident seller. A UK resident company was interposed between the US purchaser and the US target company. The UK company issued debt instruments (loan notes) to the US purchaser as…
…from the ordinary regime mentioned above is provided for in Article 51(8-bis) of the Consolidated Income Tax Act (“CITA”). That provision establishes an alternative rule for computing the tax base…
…the form of an affiliated company or a permanent establishment. To develop a common understanding, what this blueprint is about, the case study explains the new system, discussing some issues…
…Shifting Project, Tax Challenges Arising from Digitalisation – Report on Pillar Two, October 2020, OECD. Online access: http://www.oecd.org/tax/beps/tax-challenges-arising-from-digitalisation-report-on-pillar-two-Ibidem.pdf [2] See also: V. Chand, K. Romanovska, International Tax Competition in light…
…enable taxpayers, both companies and natural persons, to submit their tax returns online and communicate with the ETCB via electronic means to the largest extent. As a result of the…
…of corporate tax rates to an end. From the very beginning of its work on tax competition[1], the OECD has always limited itself to harmful tax competition. Preferential tax regimes…
…background, the Commission has recently announced a roadmap comprised of three phases. First, an “inception impact assessment” phase during which the Commission would like to receive feedback between 22 October…
…EU Commission has asked for comments on several policy options for such a mechanism. In the accompanying Inception Impact Assessment, the Commission has furthermore set out the benchmarks against which…
